In Dent v. State, No. 01-12-01043-CR, 2014 WL 346728 (Tex. App.--Houston 1st Dist. Jan. 30, 2014, no pet.), the appellant raised a number of arguments for ineffective assistance of counsel, including "that trial counsel's hearing impairment made him unable to follow the proceedings, thereby making his representation inadequate." Id. The Court found no error sufficient to satisfy the first prong of Strickland. "Trial counsel and the court in this case were proactive in resolving any problems arising from counsel's hearing impairment. Co-counsel assisted in pointing out when trial counsel was having trouble hearing, and the trial court gave co-counsel opportunities to relay the court's communications to trial counsel. Instead of holding whispered bench conferences, which trial counsel had difficulty hearing, the trial court excused the jury from the courtroom when lengthy issues arose so that discussions could take place at a normal speaking volume." Id.